Memorandum Findings of Fact and Opinion
PARR, Judge:
Respondent determined a deficiency in petitioners' 1980 Federal income tax return in the amount of $30,786.00. We must determine (1) the fair market value of 217 Caddo Indian artifacts donated to the Museum of Red River on December 12, 1980, and (2) whether the donation was a tax motivated transaction within the meaning of section 6621(c).
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